Global Privacy Notice
Effective Date: November 30, 2021
Mercer believes strongly in protecting your privacy. This Privacy Notice (the “Notice”) applies to our online surveys and our services that link to or post this Privacy Notice (collectively, the “Services”). This Privacy Notice is intended to inform you of the ways in which we collect personal information, the way we use your personal information, how and why we share that information, and the ways in which we protect it.
Please take a moment to familiarize yourself with our privacy practices. Let us know if you have any questions by contacting us at: firstname.lastname@example.org for assistance.
Since we may change this Privacy Notice, we recommend that you check the current version available from time to time. If we make changes to this Privacy Notice, we will update the “Effective Date” at the top of the page. If there are significant changes, you will be provided with appropriate notice. Your continued use of the Services constitutes your agreement to the effective Privacy Notice.
WHAT INFORMATION DOES THIS PRIVACY NOTICE COVER?
This Notice describes how we may collect, use, share, and keep information about you that we get about you. We gather information if you:
- Visit or use our Services or apps;
- Receive, send, or reply to electronic communications from us;
- Take a survey;
- Create an account as an employer or third party.
WHAT DATA DO WE COLLECT?
The information that you provide to us or that we collect or receive about you may depend on how you interact with us and in which capacity. Most of Mercer’s collection related to surveys is voluntary. Generally, we may collect the following information about you:
- contact information such as your name, email address, and phone number;
- sensitive information such as your date of birth, gender, and ethnic background;
- employment information such as employee title, employment district, and team leader;
- general survey information including information in comment boxes.
Information Provided by You, Your Representatives or Third Parties
We collect information from you; your employer; business partners; and other third parties who have an interest in surveying your satisfaction with their services. You might provide this information when you take a survey; create and manage an account; or communicate with us. In addition, your employer or someone acting on their behalf may provide us with information about you so we can contact you about our services and surveys.
Employers or third parties supplying us with personal information about other people or employees, represent that they have the authority to provide this information on their behalf. In these instances, they further represent that the individuals to whom this information relates have been informed of and understand the reason(s) for them providing or us obtaining the information, the manner in which this information will be used and disclosed, and have consented to such use and disclosure.
Survey Open Text Field
Our surveys may offer you the opportunity to provide written comments or elaborate about certain responses. We request that you do not provide information that may personally identify you or others when writing in the comment section. It is your responsibility to refrain from posting or sharing such information.
HOW DO WE USE THE DATA WE COLLECT?
We use your personal information to:
- verify your identity, when appropriate;
- provide you with products and services you request;
- allow you to manage the services you requested;
- conduct research, statistical analysis, survey/demographical interpretation, and other data studies based on the data collected;
- contact you when necessary and to respond to your requests and inquiries;
- fulfill legal and regulatory requirements;
- analyze and improve services and evaluate the effectiveness of our surveys and research and overall services.
Most of our studies are conducted with data that has been aggregated and/or de-identified. In a significant number of cases, we are unable to re-identify the data once unique identifiers have been removed and/or the data has been aggregated.
We may also use the information we collect and receive as otherwise described to you at the point of collection or pursuant to your consent.
WITH WHOM DO WE SHARE YOUR DATA?
We may share data with the employer or third party who requested the survey. We may also share your information to assist with or to provide any service you authorized, or provide other services requested by your employer, or otherwise as described in this Privacy Notice or when we have your consent. We may share this information with:
- your employer;
- our affiliates, subsidiaries, or third-party service providers that have been retained to perform services on our behalf or on behalf of your employer, or as authorized by your employer.
We may also share information in association with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
Third parties to whom we disclose information are required by law and/or contractual requirements to keep your personal information confidential and secure. These parties may not use or disclose it except as reasonably necessary to provide services to you, on our behalf, on behalf of your employer, or to comply with or as permitted by applicable law.
We do not rent, sell, or otherwise disclose your information to unaffiliated third parties for their own marketing, unless so authorized by you, or your employer.
We may disclose and/or process your personal information without your prior permission, as permitted by law, including instances when we have a good faith belief that it is necessary to: (a) protect the legal rights, safety, and security of Mercer, our affiliates and business partners, and users of our Services; (b) respond to claims of suspected or actual illegal activity; (c) respond to an audit or investigate a complaint or security threat; or (d) comply with law or legal process, or a request for cooperation by a government or other entity.
We may share information that is not reasonably likely to identify you personally for any commercially legitimate business purpose.
FOR HOW LONG DO WE RETAIN YOUR INFORMATION?
We will retain your personal information for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where we are required to retain personal information for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). Our retention periods are based on business needs and your information that is no longer needed is either de-identified (and de-identified information is retained) or securely destroyed.
WHAT RIGHTS AND OBLIGATIONS DO YOU HAVE WITH RESPECT TO YOUR DATA?
Accessing and Correcting Your Information
Keeping your information accurate and up-to-date is very important; whenever possible we will provide you with an opportunity to correct inaccurate or outdated information. However, bear in mind that if the data has been de-identified and/or aggregated it may not be possible for Mercer to track down your personal information. If you have questions or concerns regarding changes to your personal information please contact us at: email@example.com.
SOME OTHER MATTERS
Steps We Take to Protect Your Information
All information submitted by or on behalf of you may be collected, stored, and processed in countries other than the one in which you reside, including, but not limited to, the United States.
We restrict access to your personal information to those employees of ours, our affiliates, and third-party service providers who reasonably need it to provide products or services. We have implemented physical, administrative, and technical safeguards to protect your personal information from unauthorized access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of these systems, nor can we guarantee that information supplied by you or on your behalf cannot be intercepted while being transmitted over the Internet.
Does This Privacy Notice Apply to International Users?
This Privacy Notice is provided in accordance with and subject to U.S. law. If you access this Notice from a location outside the United States, you agree that your use is subject to the terms of this Privacy Notice.
If you are a resident of the European Economic Area (EEA), in order to provide our Site and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the EEA, including to the United States. Your personal information may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country. We will, in all circumstances, safeguard personal information as set out in this Privacy Notice.
Where we transfer personal information from inside the European Economic Area to outside the EEA, we are required to take specific measures to safeguard the relevant personal information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which are not subject to this approval (see the full list here: https://commission.europa.eu/select-language?destination=/node/1304), we will establish legal grounds justifying such transfer, such as MMC Binding Corporate Rules, model contractual clauses, or other legal grounds permitted by applicable legal requirements.
Please contact us at: firstname.lastname@example.org if you would like to see a copy of the specific safeguards applied to the export of your personal information.
If you have specific questions or concerns you may contact our EU Data Privacy Officer Sabrina Salhi at GDPRLegal@mmc.com.
In situations where special categories of data (such as political opinions, religious views, sex life, etc.) is collected we may request your consent. You may deny consent and choose not to provide the information requested, such decision will not affect your opportunity to participate in the survey. If you consent you still have a right to withdraw consent at any time. However, if the data has been de-identified and/or aggregated we may be unable to properly identify your survey, thereby preventing you from withdrawing consent. Data Subjects whose data has been de-identified within the meaning of the GDPR cannot claim the right to withdraw consent because their data can no longer be used to identify them.
In addition to your consent, we also rely on the need to perform our contractual obligations as well as our legitimate interests as our legal bases for processing your personal data under European data protection law.
If you have any questions in relation to our use of your personal information, you should contact us at: email@example.com. Under certain conditions, you have the right to require us to:
1.) provide you with further details on the use we make of your information;
2.) provide you with a copy of information that you have provided to us;
3.) update any inaccuracies in the personal information we hold;
4.) delete any personal information that we no longer have a lawful ground to use;
5.) object to any processing that Mercer justifies on the “legitimate interests” ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights;
6.) object to direct marketing (including any profiling for such purposes); and
7.) restrict how we use your information while we consider your inquiry;
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the data protection regulator in your country.
In the event we sell some or all of our assets or go through other business transactions, such as mergers, acquisitions, bankruptcy, or reorganizations, it is possible your personal information could be one of the assets sold or transferred in connection with the transaction. We may disclose and/or transfer your personal information to a third-party purchaser in these circumstances.
Our surveys are not intended for children, and we do not knowingly collect, use, or disclose information from children under the age of thirteen (13) years old. In an instance where such information was collected, it would be purely accidental and unintentional. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 13, please email us at: firstname.lastname@example.org .
Rights of Individuals in Certain US States:
Click here for our privacy notice regarding additional rights you may have in certain US states https://www.mercer.com/footer/us-jurisdiction-privacy-notice/
How Long Do We Keep Your Information?
We will retain your personal information for as long as is necessary for the processing purpose(s) for which it was collected and other permitted purpose(s), including retention of personal information pursuant to any applicable contract, law or regulation. Our retention periods vary based on business, legal and regulatory needs.
What Steps Do We Take to Protect Your Information?
Our surveys, and all information submitted by or on behalf of you through our surveys may be collected, stored, and processed in countries other than the one in which you reside, including, but not limited to, the United States.
We restrict access to your personal information to only those employees of ours, our affiliates, and third-party service providers who reasonably need it to provide products and/or services. We have implemented physical, administrative, and technical safeguards to protect your personal information from unauthorized access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of these systems, nor can we guarantee that information supplied by you or on your behalf cannot be intercepted while being transmitted over the Internet.
Questions or Concerns
If you have any questions, concerns, or complaints about this Privacy Notice, or our privacy practices in general, please email us at: email@example.com.